January 19, 2018

The School District of Philadelphia

New Charter School Application Evaluation Report New Charter Application for: MaST Community Charter School III

Submitted by: MaST Educational Services Provider

Application Evaluation Team: Team Lead:

Steve Coyle, Charter Schools Office

Evaluators:

Chester County Intermediate Unit Christine Woyshner, Temple University DawnLynne Kacer, Charter Schools Office Gabriela Timothy, Charter Schools Office Peng Chao, Charter Schools Office Tim Hanser, Charter Schools Office

Introduction School District of Philadelphia Overview The School Reform Commission (SRC) of The School District of Philadelphia (District) currently authorizes 84 operating charter schools serving approximately 65,000 students during school year 2017-2018.

Overview of Process The Charter Schools Office (CSO) of the District received nine (9) applications for new charter schools for the 2017-2018 new charter application cycle by the submission deadline of November 15, 2017. Each of these applications has been reviewed by a team of evaluators, led by the CSO, comprised of internal District employees and external reviewers with local and national expertise on the operation of successful charter schools. This evaluation report summarizes the assessments of the evaluation team and is limited to an evaluation of whether the application met the criteria set forth in the application instructions and certain aspects of the Charter School Law. This evaluation report is not intended to be a complete legal review of the charter application under the Charter School Law. The SRC by resolution at a public meeting will decide whether to approve or deny an application for a new charter school.

CSO Vision To create a service-oriented environment that enables the District to support and monitor charter schools while ensuring their accountability.

CSO Mission To assist the SRC and the District in meeting their legislative obligations under the Charter School Law and to promote accountability by exercising oversight for educationally sound and fiscally responsible charter schools as a means of improving academic achievement and strengthening school choice options in the District.

Evaluation Criteria Broadly, charter school applications will be evaluated on the following criteria: ● The extent to which the application considers the information requested in Section 1719-A of the Charter School Law and conforms to the legislative intent; ● The capabilities of the applicant, in terms of support and planning, to provide comprehensive learning experiences to students; ● The demonstrated, sustainable support for the charter school plan by parents, community members, and students; and ● The extent to which the charter school may serve as a model for other public schools.

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Proposal Overview Proposed School Name MaST Community Charter School III (MaST III or Charter School)

Application Summary The applicant proposes that MaST III would serve 2,600 students in Kindergarten through Grade 12 at scale. The proposed charter school would serve students beginning in the 2018-2019 school year. In Year 1, the Charter School plans to serve 1,000 students in Kindergarten through Grade 4; in Year 2, the Charter School plans to add grade 5 and serve 1,200 students; in Year 3, the Charter School plans to add Grades 6 and 9 and serve 1,600 students; in Year 4, the Charter School plans to add Grades 7 and 10 and serve 2,000 students; in Year 5, the Charter School plans to add Grades 8 and 11 and serve 2,400 students; and in the next charter term in Year 6, the Charter School would add grade 12 reaching scale as a K-12 school with a proposed maximum authorized enrollment of 2,600 students. The proposed charter school would utilize a blendedlearning model based on a STREAM-focused educational program (Science, Technology, Robotics, Engineering, Arts and Mathematics). The proposed location for the Charter School is 1 Crown Way, Philadelphia, PA, 19154 in Northeast Philadelphia. The applicant, MaST Educational Services Provider, currently manages two existing public charter schools in Philadelphia - The Math, Science and Technology Community Charter School (MaST) in Somerton and MaST Community Charter School II (MaST II) in Lawncrest. In the current school year, 2017-2018, MaST and MaST II collectively serve approximately 1,866 students. MaST’s charter expires on June 30, 2018 and is currently being evaluated for renewal. MaST II opened in school year 2016-2017 and is preparing to open a facility in Tacony for Grades 6-12. This applicant team has also submitted two amendment requests for MaST, one as part of its renewal application and the other as a separate amendment request. Both appear to be substantively similar to the request in this application and it is unclear which request if preferred.

Analysis Summary In general, evaluators found the mission and overarching academic plan components aligned to the applicant’s stated intention for the proposed educational model of MaST III – to realize the ultimate goal of preparing students with the knowledge and skills necessary for 21st Century success in higher education and the global economy via a STREAM focused curriculum. Whereas evaluators found the mission of the Charter School to be clearly stated and aligned to the educational philosophy, the mission was not reflective of all aspects of the STREAM curriculum and does not identify the students to be served by the Charter School. The applicant’s vision for the proposed charter school was not clear to evaluators; the applicant’s response to the mission and vision prompt discusses disparate educational elements in a way that does not demonstrate an overarching coherence. The review of curricular materials found that while the materials were provided generally aligned to the Pennsylvania Core standards (PA Core) and PA Academic Standards, there were gaps identified in ELA (K-4) and there was no curriculum

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provided for 4 of the 5 non-core courses that were described in the narrative as being offered, with Technology being the only one provided. The Charter School’s vision for culture and climate has strengths in regards to engaging students and families in the school culture; however, evaluators had concerns about the lack of attention given to the direct safety of students, particularly those students who may be experiencing bullying or hostile environments. In terms of Organizational Compliance, the evaluation team noted several areas of concern, some of which may lead to certain subgroups of students being disproportionately impacted. For example, the stakeholder complaint plan has no accommodation for students and families that are English Learners (ELs). Regarding Finance and Facilities, the proposed budget is credible with certain exceptions such as assumptions regarding education and EL expenditures and the structure of fees related to the proposed management agreement. The facility proposed by the Charter School has the potential to provide a strong learning environment, but the location itself is not within District’s identified areas of need for quality. Further, evaluators found the applicant provided unclear plans related to the renovation and conversion of the commercial facility at One Crown Way to a school building for use by the Charter School. MaST III has not yet identified an architect to develop plans for and to assist with the renovation of the facility. The applicant, however, still intends, if the application is approved, to open the student application process immediately (page 66). Regarding community engagement and support, the applicant provided a voluminous response but the overwhelming majority of evidence provided, such as letters of support and petitions, appear to have been written in reference to other charter schools affiliated with the applicant and not for the proposed school. For instance, many of the documents submitted are in support of the expansion of an existing charter school, not in support of granting the application of the proposed school.

Mission of the School “To create innovative pathways for students pursuing knowledge focused on Mathematics, Science, and Technology.”

Proposed Location The proposed charter school would be located at 1 Crown Way, Philadelphia, PA, 19154 in the Somerton section of Northeast Philadelphia. This location has an alternate address identified in the application of 12345 East Roosevelt Boulevard, Philadelphia, PA, 19154.

Focus of the School/Academic Program The applicant’s proposed educational philosophy is that by providing students with unique experiences, challenging content and a variety of engaging learning activities on a daily basis, it ensures that students will be well prepared for the future. The applicant purports that the curriculum is aligned to PA Core, infused with technology standards and delivered with cuttingedge best practices. The proposed charter school would adopt the STREAM model, which the applicant believes connects pathways into a Kindergarten through Grade12 continuum and promotes the development of well-rounded key elements in education that connect to real careers 4

beyond the classroom. The applicant promotes an academic plan design that is “convertible, collaborative, creative, competitive and cloud-based.”

Enrollment Projections Academic Year

Proposed Enrollment

Grades Served

2018-19

K-4

1000

2019-20

K-5

1200

2020-21

K-6; 9

1600

2021-22

K-7; 9 & 10

2000

2022-23*

K-11

2400

*The Charter School would not reach scale of grades served or maximum authorized enrollment until Year 6, 20232024, when the proposed charter school would be a Kindergarten through Grade 12 school serving 2600 students.

Proposed Opening Year ☑ 2018 - 19 ☐ 2019 – 20

New or Experienced Operator (in Philadelphia) ☐ New Operator ☑ Experienced Operator

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Section Summaries Opening and maintaining a high-performing charter school depends on having a complete, coherent plan and identifying highly capable individuals to execute that plan. The analysis below provides insight into the key strengths and weaknesses of the five main sections of the new charter applicant’s proposal.

Mission and Vision The proposed mission for MaST III is missing key elements. It was unclear to evaluators if the applicant proposes to serve all students and if so, how the mission would support all students. In stating that the mission is “creating innovative pathways for students pursuing knowledge focused on Mathematics, Science, and Technology,” evaluators were unsure if the Charter School only desires to serve students who already have foundational knowledge in the areas of math, science and technology, and if not, if the Charter School is specifically seeking and recruiting students who already have these interests so that the Charter School may fulfill its mission. Evaluators were unable to clearly identify the Charter School’s vision. While the application references the establishment of a school community that is inclusive of all and programming to prepare students for success in a global economy, evaluators were not able to identify clear, cohesive responses in the application to support these components. Both the mission statement and the presentation of concepts that comprise a response to this section of the application do not appear to contain measurable goals to allow for the proposed charter school’s consistent evaluation of success against the mission and vision. The mission statement although clear, did not specify which students would be served and how success would be measured. The broader statements of purpose the applicant presented in this section, especially concerning “preparation for higher education and the global economy in the 21st Century” did not identify through what means or measures this preparation would be assessed and validated. Further, evaluators were unsure if the applicant’s statement that the “overall focus of all MaST Schools is to close the achievement gap and provide better opportunities for student growth within the context of a safe, world class educational environment” would apply to MaST III specifically or to all charter schools operated by MaST Educational Services Provider thereby representing a purpose of the Charter School’s vendor and not the Charter School itself.

Academic Plan The proposed academic plan was generally sound in the core subject areas and technology, but failed to thoroughly exhibit alignment to the proposed mission or to relevant PA Academic Standards. The application also does not include sufficient details regarding the teaching methods, personnel or technology that would be used to support differentiation and personalized learning. Further, detailed curricular components were provided by the applicant for only one (Technology) of the five non-core courses that would be taught in Year 1 preventing evaluators from determining the alignment and appropriateness of the curriculum for these courses. Evaluators noted significant concerns about this applicant’s ability to provide a comprehensive learning experience to all students. The proposed design of the Charter School’s special education program, Response to Instruction and Intervention (RtII), service to ELs and students who are at-risk, lacked necessary detail resulting in deficiencies.

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The applicant’s proposed educational philosophy includes references to high standards, education as an effort of the school community and respect for students. The Charter School aspires to prepare students through a variety of instructional approaches and educational tools with an emphasis on the infusion and integration of technology (page 8). The application provides an overview of the Charter School’s STREAM-based curricular model that utilizes a partially blended learning model and offers a pathway to careers stating that STREAM “connects pathways into a K-12 continuum and promotes the development of well-rounded students by focusing on the entire makeup of the child” (page 3). Evaluators found that the curricular documents for all four core subjects proposed for Year 1 – English Language Arts (ELA), Math, Social Studies and Science – were generally aligned to the PA Core and PA Academic Standards. An evaluation of submitted curricular documents, however, revealed some gaps and areas of misalignment. For example, the K-4 ELA curriculum maps were not aligned with the application narrative (application narrative references Wonders ELA and Scholastic news but these are not identified in the curriculum maps). In Social Studies, unit plans did not reflect all of the standards across the proposed grade span for civics, economics, history and geography. A comprehensive set of materials pertaining to Reading and Writing for Other Subjects standards do not appear to have been included; therefore, alignment for this could not be fully evaluated. Based on what was provided, gaps were identified by evaluators for reading and writing for history and social studies. Evaluators found one elective course, the Technology class, aligned to PA Academic Standards and integrated into Science and Math; however, the application identifies four other electives – Art, Media Center/Library, Music and Physical Education – that would be offered to all students in Year 1, yet no curricular documents were submitted with the application for these subjects. As a result evaluators only had evidence of alignment to the PA Core for five of the nine subjects that would be taught at the Charter School in Year 1. Although the applicant provided evidence of the standards for the core courses to be taught in Year 1, unit plans, lesson plans, assessments and evidence of differentiation were not consistently provided for all Year 1 subjects. Sample lesson plans do not appear to have been submitted for ELA, Literature/Composition, Math, Science, Social Studies, or Technology. Unit plans for ELA (K-4), Math, Science, and Social Studies but are not present for ELA (5-8), Literature/Composition, or Technology. Similarly, materials related to the differentiation of proposed curricular were not provided with the exception of ELA (K-4) which addressed the structure of differentiated instruction within curriculum maps but did not identify specific strategies. The applicant did not clearly state the rationale for why this curriculum would be successful for the specifically proposed charter school and targeted student population nor was any evidence provided that the curriculum would meet the needs of the targeted students. Further, the applicant did not provide narrative as to how the curriculum would be adapted to ensure that the learning needs of all students who would enroll at this school would be met; as lesson plans were not provided for any subject to be taught in Year 1, evaluators could not identify planned differentiation, instructional resource levels or the planned variation in instructional practices to support students with varying needs. The applicant also did not explain why the curriculum is likely to succeed with gifted students. The applicant states only that they will “aim to accommodate all learning styles, abilities, and interests by integrating the latest technology,

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utilizing engaging instructional approaches, and hiring quality teachers and staff members.” (page 8) Evaluators found this to be a minimal description where a comprehensive statement would be expected in light of the applicant’s stated intent to serve students citywide who are the most in need of quality educational options suggesting that the school intends to target students who have not been historically well-served by their public schools. The applicant emphasized the Charter School’s intent on connecting students to careers and highlighted a desire to include hands-on learning opportunities, makerspaces, and center-based instruction. Evaluators noted the conceptual strength of this approach but found that the career pathways were not clearly defined or detailed. Evaluators noted significant deficiencies in the applicant’s response to how the Charter School would identify students that are at-risk. Evaluators found that the response does not reflect a thorough understanding of the needs of“at-risk” students, and the response did not identify the varying risk factors and types of situations Philadelphia students encounter that may impact their education. The applicant’s response focused entirely on assessing students who may face academic struggles only and discussed the Charter School’s intention to provide universal screenings, data analysis and plans for academic intervention and monitoring for students not performing at grade level. There are no references to identification or support for other types of “at-risk” students including socially or emotionally at risk students, students without permanent housing, students experiencing trauma, students with chronic health issues or students in the foster care system. The applicant describes at a high-level the basic supports the Charter School would provide for students experiencing homelessness; however, there is not an extensive discussion in the application about the processes the Charter School would use to identify, serve and support at-risk students. Based on the applicant’s identification of targeted neighborhoods and a stated intent to serve students living an hour or more away from the school to provide them with a quality school option outside of the student’s neighborhood, coupled with the aggregate early childhood risk factors for students living in these neighborhoods, the applicant’s failure to address these issues is concerning. Regarding special education services and supports, the applicant provided a plan that specifies the curriculum to be used (SAIL) for specialized instruction, an RtII system, and blended and multimodal learning strategies that will be used in the proposed charter school. Evaluators also recognized that consistent use of non-traditional classroom settings, as proposed in the application, is a positive contributor in scaffolding students with Individualized Education Programs (IEPs). However, evaluators noted that although the RtII plan for behavioral interventions was detailed, it was significantly less so for academic intervention; RtII was described only for ELA but not other core subjects; the tiers of the RtII model were not clearly delineated; and the planned accommodations, differentiation and interventions by tier and time of student in each tier were not clearly stated (pages 20 and 23). Evaluators were also concerned that the Charter School proposed to pay certified special education instructors at the same rate as general education teachers, which is already significantly below the average rate of pay for teachers in the School District (page 22). The applicant also did not address the average rate of low-incidence special education students in Philadelphia and did not identify the rate of lowincidence students served by MaST and MaST II, which are operated by the proposed charter school operator. Further, the applicant provided limited information about how students with a primary disability in each of the 13 categories would be served and did not address some categories of disability at all.

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The projected enrollment at MaST III for ELs and students receiving free and reduced price lunch (FRPL) is significantly higher than that of MaST and no evidence was presented as to how these projections for MaST III would be obtained (5-10% EL and 55-70% FRPL). Evaluators had concerns that if the projected enrollment levels were realized, the academic plan, staffing model and social-emotional supports, which are only vaguely described, would not be sufficient to meet student needs and ensure the same level of academic success MaST has achieved. It is this academic success that is provided as a primary rationale for the requested “replication” of the existing charter schools, MaST and MaST II. Evaluators did not see clear evidence in the application that the academic plan was tailored to the enrollment projections and likely student needs of the proposed charter school. The applicant does not identify any certified English as a Second Language (ESL) instructors in the budget or application narrative; however, in Year 1, the applicant proposes to serve 50-100 ELs (page 21). Further, the Language Instruction Education Program (LIEP) description is limited, does not include measures for success or academic goals for Els and does not contain the necessary level of detail to evaluate if it is consistent with PDE guidance for a LIEP (Attachment 2, Narrative page 22). Regarding academic goals and performance monitoring, evaluators found that the applicant established relevant and appropriate goals, including references to ESSA and the PA Consolidated Plan. A detailed system and structure of interventions, however, were not identified, nor were clear and consistent performance thresholds that would trigger corrective action, either directed towards staff or students. For example, the applicant states that the Charter School will engage in ongoing review of student performance (e.g. achievement, attendance, behavior), but does not provide examples of when an intervention would we warranted and by whom the intervention would be implemented (pages 34-35). The School Culture and Climate section provides a detailed description of the applicant’s ideal learning environment in terms of technology access, positive behavior systems (Panther Pride), engaging curriculum, parent outreach and teacher appreciation (page 28). While the applicant’s explanation of the proposed school environment encompasses a breadth of initiatives and pledges as to what students will experience, evaluators noted a lack of depth related to the realization of the vision for the Charter School’s culture and a plan to ensure that the various initiatives will work cohesively. The applicant also failed to describe a bullying policy or prevention program and did not include any information regarding how student input and voices would be incorporated into decision making at the school, although both areas were requested in the application template. The applicant did present a diverse range of grade and age-appropriate extracurricular activities; however, it does not appear that MaST III has expanded or initiated partnerships with the organizations that would be providing these as no Memoranda of Understanding (MOUs) were provided (even for no cost services). The applicant also did not identify if there were eligibility criteria to participate in these activities and for which students these activities would be made available (page 28). Evaluators were concerned about whether students who live in the targeted zip codes located more than one hour away by bus from the proposed facility location would be able to participate in the extracurricular activities. The applicant did not provide information about safe transportation options and anticipated travel times for such students if they participate in after-school activities. 9

Organizational Compliance Evaluators had mixed findings across the Organizational Compliance section. Notably, evaluators found the expertise of the founding coalition to be an area of strength, being that this applicant team has prior experience opening and operating charter schools in Philadelphia with the most recent charter school opening in 2016. The proposed Shared Service Agreement (SSA) between MaST and MaST III was generally strong but evaluators identified potential deficiencies related to the costs associated with the agreement. Proposed policies and practices across the domain were included but as noted herein, contain areas of concern. The proposed SSA includes terms and conditions regarding regular performance evaluations of MaST, as Shared Service Provider (SSP), and strong termination rights, including for subpar performance. The SSA also clearly identifies the roles and responsibilities of the Charter School and the SSP. Evaluators did have concerns about conflicts of interest with overlap between the current Board of Trustees for MaST and the founding board of MaST III and possibly also with the future operating board of MaST III as MaST is the SSP for MaST III. The SSA indicates (Article 1.2) that each will be governed by an independent board, but this is not supported by the information presented in the application narrative. Evaluators also noted a concern for a clause that any additional services (i.e. hourly staffing) will be billed at hourly rate. Further, the total, actual costs of the management relationship under the SSA is not clear; the budget and SSA for Year 1 identify a “management fee” of $800,000; however, every item in Article 5 of the SSA contains the language, “Shared Service Provider will invoice the school with the amount of hours worked or with an agreed upon service fee for these services” which suggests that there could be additional fees that could be invoiced and paid to the SSP. Although appropriate qualifications and role/responsibilities of the principal are identified and were included with the application, no principal candidate has been identified and no details were provided regarding recruiting, interviewing and screening of candidates for the principal position. The application merely states that the MaST team would be able to assist with these tasks. Therefore, as the application lacked an identification of specific talent partnerships, pipelines or recruitment strategies, evaluators question the Charter School’s ability to attract a high quality principal leader with sufficient experience to run a K-4 in the timeframe necessary for a successful opening. The applicant asserts that all staff will be appropriately certified and a robust advertising and recruitment plan is proposed for teaching positions. This level of certification, if realized, may go beyond the requirements of the Charter School Law (75% certification of professional staff). The Employee Handbook is detailed, comprehensive and sufficiently outlines the process for monitoring and dismissing staff. The applicant presents clear and delineated requirements for employee background checks and pre-employment clearances. It is not clear, however, makes the recommendations and has final authority for terminations of employees. The applicant identifies the reporting structures in the application, but it is not clear if this for the proposed charter school or an existing school operated by the applicant team. The employer for each position identified in the staffing model for MaST III is not clearly delineated in application. The proposed staff model is mostly developed with some inconsistencies, specifically the number of special education teachers is inconsistent and there are numerous duplicate entries in the staffing table (e.g. duplicates entries for Therapists PT, Reading Specialists and Special

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Education Aides) (page 38). There is no clear staff to student ratio identified for general or special education students or by grade level. There is a reference to self-contained, collaborative and co-teaching models, but it is not clear for what grade level or primary disabilities these various special education settings would be utilized nor how they would be staffed. Evaluators found the use of the Danielson framework for the evaluation of instructional staff coupled with the applicant’s plan to include self-evaluations to be a strength. However, there is no discussion of the Charter School’s plan to address staff turnover, and the staff improvement engagement plan lacked specific timelines for each phase of the process. The evaluation team found the staff and leadership development plans to be well-developed, including a new employee induction program and a new teacher mentor program partnership with Eastern University for principal and leadership development at no cost to staff (pages 41-42). The Professional Development topics being targeted for the proposed school are STREAM training, developing Professional Learning Communities (PLCs), RTII implementation and Inclusion Education Model, utilizing data, technology, and current trends and practices. All are identified as “ongoing” or “as needed” with the exception of staff and student need-driven workshops (Attachment 10). Additionally, the applicant intends to provide professional staff opportunities to apply for and pursue leadership roles and additional responsibilities for ongoing career development (e.g. leadership development, coaching). There is a budget item for $30,567 for Professional Development Professional Services in the Year 1 Budget. The school calendar was provided and complies with 1715-A of Act 22. The high school start time, which is 50 minutes earlier than the start time for K-8 students, does not reflect current research regarding the negative impact of early start times for high school aged students. The applicant details the responsibilities for Charter School’s attendance officer, and the proposed charter school intends to track absences in real time. Different categories of student absence are identified and the criteria for each are clearly established. The Charter School’s consequences for truancy, including suspension or expulsion from school-sponsored activities, may not be compliant with the Pennsylvania Truancy Act (page 46). Evaluators also noted an equity concern regarding the handling of student absences -whereas unexcused absences result in "disciplinary consequences", the school has a provision to allow for excused absences for family vacations, and further for these excused absences, any number of days absent would count as only one excused absence. The employee health insurance program proposed is comparable to that of the School District, is at a low cost to employees and also provides an annual stipend to employees who decline to carry MaST III health insurance. Regarding the proposed retirement benefit program, evaluators questioned whether or not the proposed school intends to offer the same 403(b) plan as MaST and if not the same, then the proposed plan is not yet PSERS approved. Also, the variable employer contribution rate makes employee benefit predictability difficult. The Charter School intends on bidding out a food service vendor and will participate in the National School Lunch Program (NSLP). It is not clear, however, whether all students will receive free lunch and/or breakfast (page 51). The applicant provides only a limited description of student health services that would be provided and no details are delineated by grade level as to which services would be provided; as such evaluators were unable to determine if the Charter School’s proposed student health services would meet state requirements for provision of student health screenings and services. Additionally and more concerning is that the Charter School has budgeted one

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nurse in Year 1 during which MaST III would enroll 1000 students across five elementary school grade levels. The evaluation team noted significant concerns for the proposed charter school's ability to meet needs of 1000 students - including medication administration, scheduling and monitoring health screenings, allergy and chronic condition monitoring, accidents at school and student illness, and development of 504 plans - with one nurse. Evaluators also flagged a concern for the potential of disproportionate effects on families of requiring a doctor’s note for over-thecounter medicines; families do not have the same access to family physicians nor the same health coverage to mitigate costs of these extraneous office visits. There is a stakeholder complaint policy provided with the application, but it is missing specific details; there is no contact information nor are the methods for submitting a complaint identified. Specific procedures for escalating a complaint or concern to the Board are not provided, and there is no provision for non-English speakers, which evaluators flagged as an equity issue. In the General Enrollment and Target Population section, the applicant provides a year-by-year enrollment table that is consistent with the application narrative and budget and identifies projected rates of enrollment by subgroup (pages 53-54). However, the subgroup enrollment rates are significantly higher than those at existing MaST operated schools with no discussion as to why these rates would be different, especially as the primary evidence of community support for MaST III is the existing applications to the current MaST schools. Additionally, evaluators were unable to determine the source of the projected enrollment rates by ethnicity as the rates presented are not reflective of School District averages, Neighborhood Network 8 averages or the averages of the applicant identified 10 targeted zip codes. The student recruiting and marketing plan for radio and TV announcements is predicated on "budget", and there no specific strategies or partner organizations identified to assist with targeted marketing to key subgroups. Evaluators also noted a lack of clarity as to what efforts would be used to access, market to and recruit students in the 10 targeted zip codes. The Admissions, Lottery and Enrollment process as presented by the applicant is clear, and the Charter School intends to use the Great Philly Schools Standard Application which is available in multiple languages. MaST III plans to backfill in all grades and at all times during the year which evaluators identify as a strength of the Admissions Policy. The evaluation team noted inconsistency in the application regarding the application of the “founders” preference, however. In the Admissions Policy it states that any staff member child has preference along with siblings of students, yet in the application narrative this staff member child preference is stated as “founders of board” which the applicant asserts never exceeded .00004% of all applicants (page 55). An all-staff preference for a school with 147 staff members in Year 1 could yield considerably more than .00004% of seats going to “founder” preference which combined with siblings of students would place unnecessary limits on school choice options for the students the most in need in Philadelphia. A Code of Conduct policy was provided by the applicant; however, it does not identify specific behaviors that could result in consequences, does not identify the specific consequences for each possible behavior and does not identify rights for students with disabilities. Although the levels of disciplinary action are identified, it is unclear what behaviors are related to which consequences, which evaluators flagged as an equity concern and prevented evaluators from determining if the level of consequence was appropriate for the level of behavior consistent with federal guidance for student discipline. The policy does include a comprehensive list of specific 12

due process rights, but beyond the due process rights listed, there is no reference to communication with families or students or how students and families will know of the expectations of the Charter School. The founding board is identified by the applicant and detailed resumes are provided; however, evident conflicts of interest with the founding board of the proposed school and MaST, the shared services provider, are not addressed. Voting parent and non-voting teacher and student members of the board are included, and areas of authority and responsibility for the Board are clearly delineated. The Board will meet monthly, and all board members will have published email addresses so that they can be reached by students, families, and other members of the community. The specific board committees that would exist initially, however, were not identified. Although the resumes of the founding board members provided relevant and necessary experience for the operation of a charter school, founding board members will transition the board to new board members upon opening the proposed school and those members and therefore their experience and expertise, are not known and could not be evaluated. In preparation for the possible closing of the school, a dissolution plan was discussed in the application, but it lacked detail and did not specifiy who would be the trustee or designee in charge or a potential dissolution, timelines for critical activities, responsible parties and associated duties or the amount and nature of the escrow account (page 62).

Finance and Facilities The applicant submitted detailed one-year and five-year budgets with cash flow and detailed benefit assumptions. The budget assumptions are in line with Philadelphia averages and the requirements of Applicable Laws. However, evaluators noted that if the projected enrollment rates and targeted student population are realized, there would significant concerns about the school's ability to sufficiently support student needs within budget. Of specific concern are historically underserved students as there are no funds budgeted for an ESL teacher even though the enrollment projection would be for 50-100 ELs in Year 1. There are no funds budgeted for any Approved Private School placements although the Charter School would enroll 1000 students in Year 1. Moreover, only $1500 per special education student is budgeted for all related services expenses which is below expected levels for an elementary school population. As previously stated, it is also unclear what if any costs beyond the flat management fee are being paid to MaST, as SSP under the SSA, and if so, where these expenses are reflected in the budget. There was no budget narrative provided to explain budget assumptions or the rationale for certain expenses although this was requested in the application. In the proposed budget submitted by the applicant, the applicant assumed revenues of $8494 for general education students and $26,983 for special education students. This is 2% more than the current School District allocation per pupil for the 2017-2018 school year. No rationale was provided for why the applicant expects both amounts to increase by the 2018-2019 school year. Given recent history, the general education per-pupil amount has generally declined. The evaluators noted there are 12 summer school/tutoring, part time positions identified in budget, but these are not mentioned in the application narrative. Additionally, there were three “Other Support Services” positions identified in the budget, but also not mentioned in the application narrative. Further, three position titles, totaling 28 positions, are listed twice in the

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narrative, but only tabulated once in the budget (page 38). Of the three duplicated positions, only one is listed as the same job category in both instances they are listed, for example, the reading specialist as an instructional job category. The other two positions have distinct job categories in each instance that they are listed. As such, evaluators were unable to determine which positions were true duplicates and which should have been reflected in the budget presented. Classroom aides are listed in the Year 1 budget with an average salary of $9,000 with no indication as to the number of hours each is expected to work. Custodians are listed as having an average salary of $22,000 which is significantly below the salary of a School District custodian. Other support services positions are listed with an average salary of $12,000; however, it is unclear if these are expected to be full-time positions. Special education aides that are identified as having co-teaching responsibilities in the application, are listed in the budget with an average salary of $22,000. This is far below the School District rate for paraprofessionals and approximately one-third the starting salary of a School District special education teacher. In the Purchased Property Services section, the applicant lists custodial services for $125,000 in Year 1, but the school also budgeted for two custodians at $22,000 each in salary. Evaluators questioned if these contracted services are above and beyond those roles and if so, what the delineation of responsibilities are for each. Utilities, except for water/sewer, should be in Supplies object but were not placed in that section. Additionally, if renovations can be capitalized, then they should be in the property section but were not. Printing was not appropriately placed in Other Purchased Serices. There is a $15,000 expense item (line 105) identified as “Other” but no explanation is provided for this expense. In the five-year budget, Year 1 is projected to end with a $20,848 fund balance on $12.1 million in revenues (0.17%). Evaluators note concerns about fund balances throughout the first five years of the charter, but otherwise the five-year budget appears sustainable. The detailed assumptions included in addition to the worksheets are thorough and transparent. As for the facility itself, evaluators reading the documentation related to the proposed site noticed that the proposed address contained in the lease agreement proposal in Attachment 33 (Facilities Intent), is a different address that is stated in the Fact Sheet attachment. In the narrative, the applicant identifies the landlord as the “owner of 12345 Roosevelt Boulevard, former Crown, Cork, & Seal building” (page 65), but then refers to the site as being “right off of the Boulevard at One Crown Way, with a signalized intersection light” (page 65). Evaluators felt it was not clear as to the true proposed location of the school. The applicant states that the proposed school will be accessible from major highways, bus routes, and a regional rail (page 66). However, Student Transpasses are not valid on Regional Rail, and the closest SEPTA subway line is approximately 37-40 minutes away by bus. Further, the neighborhood in which the Charter School proposes to operate has not been previously identified by the School District as a specific area of need. The physical space of the proposed facility is sufficient and appears to meet the requirements of the Charter School’s educational model and mission. The large, 40+ acre campus would allow for additional needs to be supported as they arise. However, the applicant’s plan for readiness of the site and facility is not clear, and there is no contingency plan/alternate location identified. There are no costs for acquisition or purchase clearly detailed and financing for the property is 14

not yet secured. The timeline for acquisition and renovations is aggressive, and the current project for MaST II has met with delays. There is no contingency presented in the budget for cost overruns. The applicant states that MaST III would apply for financing and enter a lease to buy agreement immediately with owner of 12345 Roosevelt Boulevard or would look at the use of an investor via an agreement to then buy/lease once the charter is operating and built out as fiscal stability builds over the first few years. The applicant states that it would file for zoning approval immediately and that it anticipates approval, because it has the political support in the of the building location. The Charter School would then establish interim financing prior to entering the capital markets and that they are “currently in conversation with an architect firm to assist interim development and long-term development to house 1000 students in year one across grades K-4.” The applicant continues “Once capital market financing is in place, MaST III would use funds to completely renovate the building. We would use the proven record of the MaST Administrative team, the MaST Board, and the Financial Management team of Santilli & Thomson to obtain bond financing.” Evaluators had concerns that this could all be accomplished and that the proposed school would be ready to open in the fall of 2018. (page 66)

Family and Community Engagement and Support The applicant’s response to the Community Engagement and Support section includes four hyperlinks; the first hyperlink is to a six-year-old article about school crowding and the remaining three hyperlinks are not functional (page 70). This created concerns for evaluators regarding the possibility that the information in this section was out-of-date or no longer accurate and reliable. Two additional articles that were provided as evidence of need for the proposed charter school were linked (page 7). An article Philly.com article is about overcrowding at a school serving students in grades 6-8 which is approximately seven miles away from the proposed charter school location. MaST III would not serve students in middle school grades in Year 1 and would not begin serving grades 6-8 until the 2020-2021 school year. The openinfophilly.com story is an article about Center City schools in Philadelphia, schools which are even further from the proposed MaST III location. It was not clear to evaluators why either article was included in the application since the articles did not provide relevant or compelling evidence of demand and community need for the proposed charter school. The applicant has proposed prioritizing certain zip codes (page 71), but several of the zip codes mentioned are approximately 90-120 minutes each way via public transportation from the proposed location of MaST III (e.g. 19143 and 19153). It appeared to evaluators that these targeted zip codes were identified to support the applicant’s claim that there is a need to provide quality school options to specific underserved students. The applicant did not give consideration to the resulting impact of the distance to the proposed facility for these students and their families. Of the more than 10,000 student applications submitted with the application from previous application cycles (school years) at MaST and MaST II, only 65 are from zip code 19143 or 19153. Assuming these 65 applicants are all unique applicants, that reflects less than 1% of all applicants cited as evidence of demand for the Charter School. Evaluators felt the likelihood of the student population of the proposed school being represented by these zip codes is extremely low and that the claim of targeting these zip codes lacked credibility. Evaluators were concerned that proposed inclusion of students from “school quality” deserts does not

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demonstrate what the likely demographic would be of the proposed school based on the data and evidence presented. Instead, based on the waiting list data provided by the applicant in the narrative (page 5), the demographics of the proposed school would likely be similar to that of MaST’s Byberry Road location, which currently serves a population that has an approximate poverty rate of 21%. The proposed school is assuming 55%-70% of their population will receive free and reduced lunch (page 54), which caused evaluators to question the credibility of plan. When evaluating the proposed facility and location, the evaluation team was particularly concerned by the rationale for locating the school at the proposed location. This proposed location is adjacent to MaST and approximately 9 miles northeast of MaST II, the two current locations operated by the same applicant team. The mitigation offered in the application for a school opening so far from several of the proposed target zip codes states “they (parents) are willing to commute in order to get that type of education. We have considered the fact that students need access and need to be able to get to the school from all over the city and from seeing the demand for MaST and MaST II, we know that parents will find their way to MaST no matter the location” (page 5). Evaluators note that the proposed site is more than one hour by bus from more than half of the 10 targeted zip codes and is up to two hours by public transportation in some instances. This may place an undue burden on families and students who live in other parts of Philadelphia and potentially create additional barriers. Evaluators also flagged the implied expectation, and general absence of concern, that students should travel to reach good, safe schools, without any rationale for why the Charter School will not be located in, or significantly closer to, the applicant’s targeted zip codes, especially those that are demographically more diverse and dissimilar from the applicant team’s current schools. Evaluators were concerned about the disproportionate effects of long commutes if the Charter School ends up truly serving a citywide populationa, and further, evaluators wondered how many students who took buses from farther distances would be able to participate in the full complement of proposed after-school programming, since it would require students to be picked up or to arrive home late in the evening. The impact on homework quality and reading engagement on students traveling such a distance was also not addressed by the applicant. The evaluation team also found the “if we build it, they will come” rationale to be based on conjecture and unfounded assumptions. The applicant has not provided any compelling evidence of any neighborhood or community engagement with residents or community organizations in the proposed zip codes in West and Southwest Philadelphia to determine willingness of those residents to travel such a distance for their child’s school. The evaluation team felt that this location and plan would ultimately exclude the students with the most needs and not equitably create quality new seats for all students, especially those who may currently lack a quality school option. It is unclear if the Charter School has knowledge at a detail level of the needs of the students it proposes to serve as letters of support or MOUs were not provided from potential school partner organizations or community organizations currently serving students in the targeted zip codes. There were however, numerous letters of support from elected officials and community organizations near the proposed school locations. The application includes an extensive attachment that includes a combination of letters of support from community organizations (9), elected officials (6), and residents (535). Of the documents submitted, only three (3) specify support for MaST III. The letters of support for expansion of MaST are not germane to MaST

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III as this is not an expansion of an existing charter school but rather a new charter application for a new charter school at a different location. A spreadsheet with over 8,000 names appears to be a list of students who have applied to either MaST or MaST II and again do not specify MaST III. As such, evaluators noted that there were no valid intent to enroll forms submitted for MaST III. In terms of parent and community engagement after the school would open, two parents would serve as voting Board members. There is also a wide range of proposed parent involvement events at the school including social activities, information nights, outings and sports, fundraisers and orientation. There is parent portal for access to student data. However, it is unclear how parents/families who do not speak English or who live far away from the school would be engaged in the school community.

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